Before finding that for purposes of the requirement in s. 20(1)(c)(i) that money must have been borrowed for an income-producing purpose in order to give rise to deductible interest, "income" referred to income before deductions, Iacobucci J. stated (at p. 5515):
"Nowhere in the language of the provision is a quantitative test suggested. Nor is there any support in the text of the Act for an interpretation of 'income' that involves a judicial assessment of sufficiency of income. Such an approach would be too subjective and certainty is to be preferred in the area of tax law."